SEC Comment Letter 0000000000-22-013480 to Academy Sports & Outdoors, Inc. (ASO) (CIK 0001817358) (ASO)
Academy Sports & Outdoors, Inc. (ASO) (CIK 0001817358)
Date: Dec. 14, 2022 · CIK: 0001817358 · Accession: 0000000000-22-013480
AI Filing Summary & Sentiment
File numbers found in text: 001-39589
Letter
United States securities and exchange commission logo December 14, 2022 Michael Mullican Chief Financial Officer Academy Sports and Outdoors, Inc. 1800 North Mason Road Katy, TX 77449 Re:Academy Sports and Outdoors, Inc. Form 10-K for Fiscal Year Ended January 29, 2022 Filed March 29, 2022 Form 10-Q for the Fiscal Quarter Ended July 30, 2022 Filed September 7, 2022 File No. 001-39589 Dear Michael Mullican: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for Fiscal Year Ended January 29, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations 2021 (52 weeks) Compared to 2020 (52 weeks) Net Sales, page 50 1.We note that you disclose the increase in net sales "was driven by an increase in both transactions and average ticket." Please quantify the amount attributable to changes in volume of goods sold and changes in pricing. Refer to Item 303(b)(2)(iii) of Regulation S-K.
FirstName LastNameMichael Mullican Comapany NameAcademy Sports and Outdoors, Inc. December 14, 2022 Page 2 FirstName LastName Michael Mullican Academy Sports and Outdoors, Inc. December 14, 2022 Page 2 Form 10-Q for the Fiscal Quarter Ended July 30, 2022 Non-GAAP Measures Adjusted EBITDA and Adjusted EBIT, page 31 2.Please explain to us why you believe adjusting for pre-opening costs is appropriate considering your growth strategy is based on the opening of new stores, and these costs would appear to be normal, recurring cash operating expenses necessary for your core operations. We note you have opened two new stores and intend to open nine stores in 2022. Refer to Question 100.01 of the Staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Rene Casares, General Counsel
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United States securities and exchange commission logo
December 14, 2022
Michael Mullican
Chief Financial Officer
Academy Sports and Outdoors, Inc.
1800 North Mason Road
Katy, TX 77449
Re:Academy Sports and Outdoors, Inc.
Form 10-K for Fiscal Year Ended January 29, 2022
Filed March 29, 2022
Form 10-Q for the Fiscal Quarter Ended July 30, 2022
Filed September 7, 2022
File No. 001-39589
Dear Michael Mullican:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended January 29, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
2021 (52 weeks) Compared to 2020 (52 weeks)
Net Sales, page 50
1.We note that you disclose the increase in net sales "was driven by an increase in both
transactions and average ticket." Please quantify the amount attributable to changes in
volume of goods sold and changes in pricing. Refer to Item 303(b)(2)(iii) of Regulation
S-K.
FirstName LastNameMichael Mullican
Comapany NameAcademy Sports and Outdoors, Inc.
December 14, 2022 Page 2
FirstName LastName
Michael Mullican
Academy Sports and Outdoors, Inc.
December 14, 2022
Page 2
Form 10-Q for the Fiscal Quarter Ended July 30, 2022
Non-GAAP Measures
Adjusted EBITDA and Adjusted EBIT, page 31
2.Please explain to us why you believe adjusting for pre-opening costs is appropriate
considering your growth strategy is based on the opening of new stores, and these costs
would appear to be normal, recurring cash operating expenses necessary for your core
operations. We note you have opened two new stores and intend to open nine stores in
2022. Refer to Question 100.01 of the Staff's Compliance and Disclosure Interpretations
on Non-GAAP Financial Measures.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Rene Casares, General Counsel